Regulated health professionals are able to transfer the authority to perform a controlled act to another person. That process is called delegation.

Delegations must be made in accordance with any regulations under the Act governing that profession.  (See also Exceptions to the Restriction.) For naturopaths, Part III of the General Regulation establishes the rules for both delegating a controlled and accepting a delegation.

It is important to note that some regulated health professions have limitations on what can be accepted as a delegated act.  

What is a Controlled Act?

Under Ontario law, only authorized health¬ care professionals can perform 13 “controlled acts”. With the appropriate education and training, different health care professionals may be permitted to perform certain controlled acts, in whole or part.  

Controlled acts are procedures that inherently carry a risk of harm. Therefore, they are restricted to professionals who have the knowledge, skill and judgment to perform a particular act safely, ethically and competently.

Exceptions to the Restriction

Any person may perform a controlled act that is otherwise restricted if they are:
  • Providing first aid or temporary assistance in an emergency.
  • Fulfilling the educational requirements to become a member of a regulated health profession, and the controlled act is: 1) within the scope of practice; 2) done while under supervision of a member of the profession.
  • Treating a person by prayer or spiritual means according to the beliefs of the person providing the treatment, i.e. an exemption for pastoral or religious providers.
  • Treating a member of their own household, provided they are: 1) communicating a diagnosis; 2) administering a substance by injection or inhalation; or 3) inserting an instrument, hand or finger into an opening of the body.
  • Assisting a person with routine activities of daily living, and: 1) administering a substance by injection or inhalation; or 2) inserting an instrument, hand or finger into an opening of the body.

The Difference Between Delegations and Referrals

Asking someone else to perform a controlled act is not always a delegation. When a member of a regulated health profession asks another member of the same profession to perform a controlled act, it is not necessarily a delegation but a referral.

It is also a referral when a member of a regulated health profession makes the request of a member of another regulated health profession authorized by law to perform the same controlled act. In this instance, the regulated health profession who is receiving the referral must perform any controlled act in accordance with the rules governing that profession.

A transfer of care for a patient from one naturopath to another is therefore a referral. The naturopath receiving the transfer is responsible for treatment and decisions about what care to provide, including whether to perform a controlled act, and performs any controlled acts under his or her own authority.

A naturopath who has met the standards of practice for therapeutic prescribing and intravenous infusion therapy can not delegate the performance of those controlled acts to another naturopath. The receiving naturopath must only perform those controlled acts if he or she too has met those standards.